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Ohio Case Law

State v. Coomes, 2025-Ohio-2470

Case Information

Court: Court of Appeals Delaware County, Ohio Fifth Appellate District
Date: 2025-07-11
Citation: 2025-Ohio-2470
Read the Opinion

Summary

Summary: The Defendant appealed the denial of her motion for substitute counsel prior to pleading guilty to 14 counts of child endangerment; the appellate court affirmed the trial court’s ruling, finding no abuse of discretion.

Key Holdings

  • A guilty plea waives appealable errors unless they affect the voluntariness of the plea
  • A motion for substitute counsel requires a showing of good cause such as conflict or breakdown in communication
  • Trial courts have discretion to deny untimely or unsupported motions for substitute counsel
  • Statements during plea colloquy showed the plea was knowing and voluntary

More Information

The Defendant was indicted in Delaware County for multiple counts of child endangerment stemming from alleged abuse at her in-home daycare between 2021 and 2023. After initial charges were dismissed, a second indictment followed with three kidnapping and fourteen child endangerment counts. Much of the alleged abuse was captured on video. The Defendant was appointed counsel after her private attorney withdrew.

Before her scheduled plea hearing, the Defendant sought to substitute counsel, but the court declined due to the late timing and lack of a formal request. Following a recess, she agreed to proceed with the plea. She pled guilty to all 14 counts of child endangerment, with the State dismissing the kidnapping charges. She was sentenced to 42 years in prison—three years per count, served consecutively.

On appeal, the Defendant claimed the court abused its discretion by denying her motion for substitute counsel without proper inquiry. The appellate court held that no good cause was shown for new counsel and that the motion was untimely. It further noted that the Defendant expressed satisfaction with her attorney during the plea colloquy and confirmed the voluntariness of her plea.

The appellate court found no abuse of discretion and affirmed the trial court’s decision.